Staff at FSC-US circulated a letter last week that provides updated information, including one more extension to the ongoing cascade of deadline extensions.You can download and read a copy of the letter here.The key points are:

The US-NRA received “conditional approval” on 7 Dec. 2018, but conditions for approval remain unmet.Staff are negotiating details and “expecting” final approval in January 2019.

CRA’s now in place will continue to be valid until at least June 2019 and potentially as long as 6 months after the US-NRA receives its approval from FSC-IC (see UPDATE below).

A temporary stakeholder support agreement worked out in 2018 to assist Low Risk conclusions for CRAs in Category 3 (HCV) has also been extended – in this case to 28 Feb. 2019.

This latest delay should quickly become a minor and forgotten wrinkle in this long, long saga.Several wildcards remain in the deck, however:

What are the “conditions” that FSC-IC is imposing on FSC-US?Will they impact the practical application of the new NRA and (especially) the Control Measure framework?

Will the three NGO signatories of the CRA Stakeholder letter remain collaborative?Are their expectations consistent with a practical roll-out of the new standard?

How will the final US-NRA differ from the still-in-development NRA for Canada?What effect will this have on cross-border trade in the coming year?

Plenty of scope for drama in the coming weeks and months.Please stay tuned and stay in touch.

UPDATE (12 January 2019): We received the following note yesterday from staff at FSC-US asking us to update the details concerning the final expiration of Company Risk Assessments (CRAs):

We (FSC US) received confirmation from FSC International’s Performance and Standards Unit (PSU) that, “Certificate holders have 6 months from the date of approval of the NRA to update their DDS. So, even if the 6 months period extends beyond June 30, 2019 also, certificate holders can still continue to use the company risk assessments till that transition period is over.”